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307 North Michigan Ave., Suite 1020 Washington, DC 20036 Chicago, Illinois 60601 Telephone: (202) 872-6811 Barbara S. Esbin Telephone: (312) 372-3930 Admitted in the District of Columbia Facsimile: (202) 683-6791 Facsimile: (312) 372-3939

February 23, 2011

Via ECFS

Marlene Dortch Secretary Federal Communications Commission 445 12th Street, SW Room TW-A325 Washington, DC 20554

Re: American Cable Association (“ACA”) Notice of Ex Parte Presentation; In the Matter of Rulemaking to Amend The Commission’s Rules Governing Retransmission Consent; MB Docket No. 10-71.

Dear Ms. Dortch:

On February 22, 2011, Ross Lieberman, American Cable Association; Thomas Cohen, Kelley Drye & Warren, LLP; and the undersigned met with Joshua Cinelli, Media Advisor to Commissioner Copps; Jennifer Tatel, Legal Advisor-media issues to Commissioner Baker, Dave Grimaldi, Media Legal Advisor to Commissioner Clyburn; and Marilyn Sonn, Acting Legal Advisor for Media to Chairman Genachowski.

During the meeting, ACA discussed the issues raised in its comments filed in support of the Petition for Rulemaking and as reflected in its ex parte letter filed February 16, 2011, including the matters of (i) retransmission consent price increases resulting from joint negotiations involving multiple “Big 4” (i.e., ABC, NBC, CBS, and FOX) broadcast affiliates in a single market, and (ii) retransmission consent price discrimination against smaller multichannel video programming distributors (“MVPDs”).1 ACA presented information derived from the analysis of its economic expert, Professor William P. Rogerson, Northwestern University, that was submitted with the ACA February 16th Ex Parte Letter and

1 In the Matter of Petition for Rulemaking to Amend the Commission’s Rules Governing Retransmission Consent, MB Docket No. 10-71, Comments of the American Cable Association (filed May 18, 2010) (“ACA Comments”); In the Matter of Petition for Rulemaking to Amend the Commission’s Rules Governing Retransmission Consent, MB Docket No. 10-71, American Cable Association Notice of Ex Pate Presentation (filed Feb. 16, 2011) (“ACA February 16th Ex Parte Letter”).

Marlene Dortch February 23, 2011 Page 2 also attached to this letter as Attachment A.2 ACA also discussed how the Commission could provide effective relief through changes to its definition of “good faith” negotiations to prevent joint retransmission consent negotiations and prevent undue price discrimination against smaller MVPDs and their subscribers.

With respect to the problems of joint negotiations and price discrimination, ACA urged the Commission, as part of this proceeding, to gather data that would allow it to determine the extent and magnitude that both matters affect retransmission consent fees, should it determine that such information is necessary to inform its decision. ACA stated that many of its members would be willing to file their retransmission consent agreements with the Commission for this specific purpose. ACA suggested that the Commission establish in the NPRM confidentiality safeguards for highly sensitive data comparable to those used in its license transfer reviews and another recent matter,3 and encourage broadcasters to waive any confidentiality provisions contained within these contracts that would prevent the voluntary submission of a contract into the record by an MVPD.

In summary, ACA stressed that it is incumbent upon the Commission, as it undertakes its first major evaluation of the retransmission consent framework, to include in its Notice of Proposed Rulemaking:

 language that expressly solicits comments on carriage fee increases resulting from joint negotiations involving multiple “Big 4” broadcast affiliates in a single market and price discrimination against smaller MVPDs; and

 language that seeks data from MVPDs and broadcasters to analyze these issues.

2 William P. Rogerson, Professor of Economics, Northwestern University, “Two Problems with the Current Retransmission Consent Regime,” Presentation to the FCC, American Cable Association, February 12, 2011 (“Rogerson Presentation”). 3 See, e.g., In the Matter of Special Access for Price Cap Local Exchange Carriers, WC Docket No. 05- 25, AT&T Corp. Petition for Rulemaking to Reform Regulation of Incumbent Local Exchange Carrier Rates for Interstate Special Access Services, RM-10593, Second Protective Order, (rel. Dec. 27, 2010) (“Second Protective Order”); Data Requested in Special Access NPRM, Public Notice, WC Docket No. 05-25, RM-10593, DA 10-2073 (rel. Oct. 28, 2010). To ensure, as part of its pending Special Access rulemaking proceeding, that it could analyze the extent of competition in markets for the provision of special access telecommunication services, the Commission recently established a process that encouraged the filing of relevant confidential and proprietary ("competitively sensitive") information. First, the Commission issued a request to the public to submit voluntarily extensive and detailed information about special access facilities deployment and use, both current and planned. Second, because the Commission found that submission of such information, even if competitively sensitive, was “necessary to develop a more complete record on which to base the Commission’s decision in this proceeding and therefore require production,” it adopted a Second Protective Order “to ensure that certain highly confidential and competitively sensitive documents and information that may be submitted are afforded adequate protection.” Second Protective Order, ¶¶ 1, 3. As part of this order, the Commission enabled parties submitting materials of a competitively sensitive nature to designate those materials as Highly Confidential, and it limited access to that material to “Outside Counsel of Record, their employees, and Outside Consultants whom they retain to assist them in this proceeding.” Id., ¶ 3.

CINNAMON MUELLER Marlene Dortch February 23, 2011 Page 3

If you have any questions, or require further information, please do not hesitate to contact me directly. Pursuant to section 1.1206 of the Commission’s rules, this letter is being filed electronically with the Commission.

Sincerely,

Barbara S. Esbin

Enclosure cc (via email): Joshua Cinelli Jennifer Tatel Dave Grimaldi Marilyn Sonn

CINNAMON MUELLER

ATTACHMENT A

TWO PROBLEMS WITH THE CURRENT RETRANSMISSION CONSENT REGIME

Presentation to the FCC

American Cable Association

February 15, 2011 INTRODUCTION

1. Conclusions of Petition for Rulemaking

- changes in market structure that have occurred since the introduction of the current retransmission consent framework have fundamentally altered the balance of bargaining power between local broadcasters and MVPDs in favor of local broadcasters

- increased competition in the MVPD market has reduced the bargaining power of MVPDs

- Result #1: Retransmission consent fees are rising to much higher levels than were ever originally contemplated when the current rules were introduced. These fee increases are largely passed through to subscribers in the form of higher subscription fees. - Result #2: Increasing occurrence of temporary withdrawals of broadcast signals during negotiations in which broadcasters attempt to exercise their increase bargaining power.

2. Petition suggests that introducing some form of binding arbitration with mandatory interim carriage would be an appropriate solution to these problems.

1 INTRODUCTION (CONT’D)

3. ACA agrees with the conclusions of the petition for rulemaking and supports the proposed solution of introducing some form of binding arbitration with mandatory interim carriage.

4. Purpose of today’s presentation:

- describe two additional problems with the current retransmission consent regime that the Commission should also consider addressing in its over-all review of retransmission consent policy - joint control or ownership of multiple Big 4 broadcast stations in the same market - price discrimination

- suggest approaches the Commission could take to addressing these problems

- although these problems with the current system have existed since its inception, they have grown more serious in magnitude as retransmission consent fees have risen and will continue to grow more serious in magnitude as retransmission consent fees continue to rise further.

2 JOINT CONTROL OR OWNERSHIP OF MULTIPLE BIG 4 BROADCASTERS IN THE SAME MARKET

1. Background

2. Evidence on the Extent of Joint Control or Ownership

3. The Problem With Joint Control or Ownership: Theory

4. The Problem with Joint Control or Ownership: Evidence

5. Possible Solutions

3 BACKGROUND

1. Joint Ownership

- Commission rules generally prohibit common ownership of multiple Big 4 broadcast stations in the same DMA - however, there are a number of instances where common ownership has been permitted through waivers or exceptions

2. Joint Control - separately owned Big 4 broadcast stations in the same DMA sometimes agree to jointly negotiate retransmission consent agreements. - such arrangements are often negotiated as part of more comprehensive agreements that transfer control of all or part of the operations of one station to the management of another stations - terms used to describe such agreements include: - Shared Services Agreements (SSAs) - Local Marketing Agreements (LMAs) - Joint Marketing Agreements (JMAs)

4 EVIDENCE ON THE EXTENT OF JOINT CONTROL OR OWNERSHIP

1. Using publicly available documents, ACA has complied a listing of instances of common ownership or control of multiple Big 4 broadcast stations in the same DMA.

2. See Tables 1 and 2 attached to these slides.

3. Summary of findings - instances of joint control or ownership - 36 instances of common ownership - 57 instances of joint control - 93 instances in total - how these instances are spread across the 210 DMAs - 16 DMAs with two instances of joint control or ownership - 62 DMAs with one instances of joint control or ownership - 78 DMAs with at least one instance of joint control or ownership

5 THE PROBLEM WITH JOINT CONTROL OR OWNERSHIP: THEORY

1. Retransmission consent fees are determined by bilateral bargaining.

2. Standard economic theory of bilateral bargaining shows that the negotiated prices for two networks will be higher if the networks are sold together instead of separately so long as the networks are “partial substitutes” in the sense that the marginal value of either of the networks to the MVPD is lower conditional on already carrying the other network.

3. Example: - MVPD can carry two networks - profit from carrying one network = $1.00 per sub - profit from carrying both networks = $1.50 per sub - note that the networks are partial substitutes - marginal value of first network = $1.00 - marginal value of second network = $.50 - assume MVPD and programmer have equal bargaining strength (i.e., they split the joint surplus from any agreement.)

6 THE PROBLEM WITH JOINT CONTROL OR OWNERSHIP: THEORY (CONT’D)

4. Case #1: A different programmer owns each network

- total surplus from adding a network = $.50 - negotiated fee for a network = $.25 - total cost of purchasing both networks = $.50

5. Case #2: One programmer owns both networks

- total surplus from adding a bundle of both networks = $1.50 - negotiated fee for bundle of both networks = $.75 - total cost of purchasing both networks = $.75

6. In its analysis of the Comcast-NBCU transaction, the Commission accepted this analysis as being theoretically correct

7 THE PROBLEM WITH JOINT CONTROL OR OWNERSHIP: EVIDENCE

1. Suddenlink Ex Parte Filing: - joint control or ownership of Big 4 stations in the same DMA results in retransmission consent fees that are 21.6% higher than when there is no joint control or ownership

2. Commission Analysis in the Comcast-NBC transaction - issue in the Comcast-NBUC was whether joint control of an RSN and Big 4 local broadcast station in the same DMA would result in higher fees - Commission analysis showed there was evidence for such an effect - it is even more likely that the partial substitutes condition will be satisfied by two Big 4 broadcast networks

3. DOJ Has Determined That Joint Control of Retransmission Consent Fees Is Anticompetitive - In 1996, DOJ filed a complaint against three Big 4 broadcast stations in Corpus Christi DMA alleging that they had illegally colluded to raise retransmission consent fees by entering into an agreement to jointly negotiate these fees. - the three broadcast stations signed a consent decree agreeing to halt this practice

8 THE PROBLEM WITH JOINT CONTROL OR OWNERSHIP: EVIDENCE

4. ACA strongly urges the Commission, as part of this proceeding, to gather data that would allow it to develop its own independent empirical measure of the extent to which joint control or ownership of multiple Big 4 broadcast stations in the same DMA results in higher retransmission consent fees.

9 POSSIBLE SOLUTIONS

1. Binding arbitration with mandatory interim carriage - could help control increases in retransmission consent fees due to both common ownership of multiple Big 4 broadcasters in the same DMA and joint negotiation of retransmission consent prices by separately owned Big 4 broadcast stations in the same DMA.

2. Redefine the “good faith” requirement for negotiating retransmission consent deals to prohibit separately owned Big 4 broadcast stations in the same DMA from jointly negotiating retransmission consent fees - prohibition should apply even if broadcasters enter into agreements that allow some cooperative activities - there is a danger that broadcasters participating in a cooperative agreement would be able to informally coordinate their retrans negotiations even if they are required to conduct separate negotiations. - help prevent this by prohibiting broadcasters participating in a cooperative agreement from discussing or sharing information of any sort about retrans negotiations or prices - this would control fee increases due to joint negotiations but would not control fee increases due to common ownership.

10 TWO REMARKS ON REDEFINING THE GOOD FAITH REQUIREMENT TO PREVENT SEPARATELY OWNED BROADCAST STATIONS FROM JOINTLY NEGOTIATING RETRANS AGREEMENTS

1. One possible argument that the Commission does not have authority to enact such a regulation is incorrect. - possible argument: - both current regulations and the underlying act specifically state that price discrimination is allowed so long as it is based on “competitive marketplace considerations.” - one might try to argue that allowing broadcasters to jointly negotiate prices is simply allowing normal competitive markets to function. - this is NOT correct - allowing separately owned sellers to enter into price- fixing agreements frustrates the operation of competitive markets

2. This solution would still allow potential efficiencies from other types of cooperative joint activities to occur. - the new rule would prohibit firms in a cooperative agreement from jointly negotiating retransmission consent prices - it would not prohibit them from other potential forms of cooperation that might be efficient

11 PRICE DISCRIMINATION

1. Background

2. Evidence on the Extent of Price Discrimination

3. Price Discrimination in Retransmission Consent Fees Does Not “Expand the Market”

4. The Problem with Price Discrimination

5. Possible Solutions

12 BACKGROUND

1. Small and medium size MVPDs generally have significantly less bargaining power than their larger competitors because the share of the audience they provide to a typical broadcast station is small enough that the loss of this audience will not generally have any significant impact on the station’s advertising revenue.

2. The result is that small and medium sized MVPDs are often required to pay retransmission consent fees that are significantly higher that the fees that larger MVPDs are required to pay for permission to retransmit exactly the same broadcast signal.

3. Differences in retransmission consent fees cannot be explained by differences in costs of providing retransmission consent to MVPDs of different sizes

- local broadcasters experience no direct cost of providing retransmission consent to any MVPD - MVPD is responsible for downloading the signal itself - differential negotiation costs likely to be very small

13 EVIDENCE ON THE EXTENT OF PRICE DISCRIMINATION

1. Universal use of non-disclosure clauses severely limits amount of publicly available information on retransmission consent fees.

2. Kagan Estimates of Average Per Subscriber Retransmission Consent Fees for 2010

Type of MVPD Retrans. Fee ($ per sub per mo.)

Large Cable .14 DBS .25 Telco .30

3. Based on anecdotal evidence from its membership ACA believes that average retransmission consent fees paid by its members are at least as high as $.30 per subscriber per month.

4. ACA strongly urges the Commission, as part of this proceeding, to gather data that would allow it to determine the extent and magnitude of price discrimination in retransmission consent fees if it determines that such information is necessary to inform its decision.

14 PRICE DISCRIMINATION IN RETRANSMISSION CONSENT FEES DOES NOT “EXPAND THE MARKET”

1. Traditionally cited benefit of price discrimination is that it may allow the firm to “expand the market” - firm is willing to sell to certain buyers with a low willingness to pay because it is still able to charge high prices to buyers with a high willingness to pay.

2. This possible benefit does NOT apply to price discrimination in retransmission consent fees.

3. Since the vast bulk of MVPD subscribers are provided by larger MVPDs, local broadcasters would obviously be willing to continue to supply retransmission consent to larger MVPDs even if they were required to offer similarly low fees to smaller MVPDs.

15 THE PROBLEM WITH PRICE DISCRIMINATION

1. Increases in retransmission consent fees are substantially passed through to subscribers in the form of higher subscription prices.

2. Allowing price discrimination in retransmission consent agreements therefore essentially means that subscribers of smaller MVPDs pay more for the right to view local broadcast signals than do subscribers of larger MVPDs.

3. While there may be a good policy rationale for requiring MVPD subscribers to make payments to help support the programming efforts of local broadcasters, the rationale for requiring customers of small and medium size MVPDs to make larger payments than the customers of large MVPDs is much less apparent.

4. The distinction between retransmission consent fees and fees for other programming: - government has provided local broadcasters with many more advantages and protections than it has provided to other programmers - generally recognized that government in return has the right to make greater demands on local broadcasters to serve the public interest

16 POSSIBLE SOLUTIONS

1. Prohibit entirely or place limits on the amount of price discrimination that local broadcasters are allowed to engage in.

17 CONCLUSION

1. Besides the problems with retransmission consent identified in the petition for rulemaking, the ACA has identified two additional problems with retransmission consent that the Commission should consider addressing in this proceeding.

2. Problem #1: Joint control or ownership of Multiple Big 4 Broadcasters in the same DMA

- results in higher retransmission consent fees which are substantially passed through to subscribers in the form of higher subscription fees.

- possible solutions - binding arbitration proposal of the petition for rulemaking would address this problem - “good faith” requirement for negotiations could be modified to prohibit separately owned Big 4 broadcast stations in the same DMA from jointly negotiating retransmission consent fees.

18 CONCLUSION (CONT’D)

3. Problem #2: Price Discrimination - because they have less bargaining power, smaller MVPDs are charged higher retransmission consent fees than are larger MVPDs - retransmission consent fees are passed substantially through to subscribers in the form of higher subscription fees - result: customers of small MVPDs are required to make higher payments to support the programming efforts of local broadcasters than are customers of large MVPDs - possible solutions: - prohibit entirely or place limits on the amount of price discrimination that local broadcasters are allowed to engage in

19 36 Identified Instances of Common Ownership of Multiple Big 4 Affiliates in the Same Market

Station or Signal #1 Station or Signal #2 DMA DMA Rank Station(s) Owner Call Letters Affil. Call Letters Affil. Raleigh‐Durham (Fayetteville), NC# 26 Capital Broadcasting WRAL CBS WRAZ FOX Grand Rapids‐Kalamazoo‐Battle Creek, MI# 41 LIN Media WOOD NBC WOTV ABC Norfolk‐Portsmouth‐Newport News, VA# 43 LIN Media WAVY NBC WVBT FOX Albuquerque‐Santa Fe, NM# 44 LIN Media KASA FOX KRQE CBS Jacksonville, FL# 47 Gannett Co. WJXX ABC WTLV NBC Youngstown, OH*@ 110 WKBN 27.1 CBS WKBN 27.2 (WYFX‐LP) FOX Santa Barbara‐Santa Maria‐San Luis Obispo, CA# 120 Cowles Media KKFX Fox KCOY CBS Topeka, KS*+ 136 New Vision Television KSNT 27.1 NBC KSNT 27.2 (KTMJ‐CA) FOX Beaumont‐Port Arthur, TX* 141 London Broadcasting Co. KBMT 12.1 ABC KBMT 12.2 NBC Palm Springs, CA*+ 142 News‐Press & Gazette Co. KESQ 42.1 ABC KESQ 33.2 (KDFX‐CA) FOX Salisbury, MD* 144 Draper Holdings Business Trust WBOC 16.1 CBS WBOC 21.2 FOX Bluefield‐Beckley‐Oak Hill, WV* 156 West Virginia Media Holdings WVNS 59.1 CBS WVNS 59.2 FOX Binghamton, NY# 157 LLC WIVT ABC WBGH‐CA NBC FOX & Wheeling, WV‐Steubenville, OH* 159 West Virginia Media Holdings WTRF 7.1 CBS WTRF 7.2 & 7.3 ABC Sherman, TX‐Ada, OK* 161 KXII 12.1 CBS KXII 12.3 FOX Sherman, TX‐Ada, OK* 161 Lockwood Broadcasting Group KTEN 10.1 NBC KETN 10.3 ABC Yuma, AZ‐El Centro, CA* 164 News‐Press & Gazette Co. KECY 9.1 FOX KECY 9.2 ABC Clarksburg‐Weston, WV# 168 Withers Broadcasting Co. WDTV CBS WVFX FOX Clarksburg‐Weston, WV* 168 West Virginia Media Holdings WBOY 12.1 NBC WBOY 12.2 ABC Quincy, IL‐Hannibal, MO‐Keokuk, IA* 171 Group KHQA 7.1 CBS KHQA 7.2 ABC Quincy, IL‐Hannibal, MO‐Keokuk, IA* 171 Quincy Newspapers WGEM 10.1 NBC WGEM 10.3 FOX Harrisonburg, VA* 178 Gray Television WHSV 3.1 ABC WHSV 3.2 FOX Alexandria, LA* 179 Corp. KALB 5.1 NBC KALB 5.2 CBS Marquette, MI* 180 Barrington Broadcasting KLUC 6.1 NBC KLUC 6.2 FOX Bowling Green, KY* 182 Gray Television WBKO 13.1 ABC WBKO 13.2 FOX Bowling Green, KY* 182 Max Media WNKY‐DT 40.1 NBC WNKY‐DT 40.2 CBS Charlottesville, VA*@ 183 Gray Television WCAV 19.1 CBS WCAV 19.3 (WAHU‐LP) FOX Charlottesville, VA*@ 183 Gray Television WVAW‐LD 16.1 ABC WVAW‐LD 16.2 (WCAV 19.1) CBS #Common Ownership Thru w/ Full Power Station @Common Ownership Thru Duopoly w/ Low Power Station +Common Ownership Thru Duopoly w/ Class A Station *Common Ownership Achieved Thru a Primary Video and Multicast Stream 36 Identified Instances of Common Ownership of Multiple Big 4 Affiliates in the Same Market

Station or Signal #1 Station or Signal #2 DMA DMA Rank Station(s) Owner Call Letters Affil. Call Letters Affil. Meridian, MS# 185 Michael Reed (WGBC‐TV) WGBC 30.1 FOX WMDN CBS Meridian, MS* 185 Michael Reed (WGBC‐TV) WGBC 30.1 FOX WGBC 30.2 NBC

Greenwood‐Greenville, MS* 187 Commonwealth Communications WAGB 6.1 ABC WAGB 6.2 FOX Bend, OR*@ 189 News‐Press & Gazette Co. KTVZ 21.1 NBC WTVZ 21.3 (KFXO‐LP) FOX Parkersburg, WV* 194 Gray Television WTAP 15.1 NBC WTAP 15.2 FOX Mankato, MN* 199 Corp. KEYC 12.1 CBS KEYC 12.2 FOX Victoria, TX*@ 204 Saga Communications KAVU 25.1 ABC KAVU 25.2 (KMOL‐LP) FOX North Platte, NE+ 209 Hoak Media Corp. KNOP NBC K11TW FOX

#Common Ownership Thru Duopoly w/ Full Power Station @Common Ownership Thru Duopoly w/ Low Power Station +Common Ownership Thru Duopoly w/ Class A Station *Common Ownership Achieved Thru a Primary Video and Multicast Stream 57 Identified Instances of Common Control of Multiple Big 4 Network Stations in the Same Market

Station #1 Station #2 DMA DMA Rank Owner (also Controlling Entity) Call Letters Affil. Owner Call Letters Affil. Columbus, OH 34 WSYX ABC Cunningham Broadacsting Corp. WTTE FOX Jacksonville, FL 47 Newport Television WAWS FOX High Plains Broadcasting WTEV CBS Providence, RI‐New Bedford, MA 53 LIN TV Corp WPRI CBS WNAC WNAC FOX Wilkes Barre‐Scranton, PA 54 NexStar Broadcasting Group WBRE NBC WYOU CBS Charleston‐Huntington, WV 63 Sinclair Broadcast Group WCHS ABC Cunningham Broadacsting Corp. WVAH FOX Ft. Myers‐Naples, Fl 64 Waterman Broadcasting Co. WBBH NBC Montclair Communications, Inc. WZVN ABC Dayton, OH 65 Sinclair Broadcast Group WKEF ABC Cunningham Broadacsting Corp. WRGT FOX , HI 71 KHNL NBC MCG Capital KGMB CBS Springfield, MO 74 Schurz Communications KYTV NBC Perkin Media KSPR ABC Springfield, MO 74 NexStar Broadcasting Group KSFX FOX Mission Broadcasting KOLR CBS Rochester, NY 80 NexStar Broadcasting Group WROC CBS Sinclair Broadcast Group WUHF FOX Syracuse, NY 83 Barrington Broadcasting WSTM NBC Crop. WTVH CBS Cedar Rapids‐Waterloo‐ City and Dubuque, IA 88 Sinclair Broadcast Group KGAN CBS Second Generation Iowa KFXA FOX

Tri‐Cities, TN‐VA 93 Bonten Media Group WCYB NBC Esteem Broadcasting of North Carolina WEMT FOX Burlington, VT‐Plattsburgh, NY 94 WFFF FOX Lambert Broadcasting of Burlington WVNY ABC Baton Rouge, LA 95 Communication Corp of America WGMB FOX White Knight Broadcasting WVLA NBC Savannah, GA 96 New Vision Television WJCL ABC Parkin Broadcasting WTGS FOX El Paso, TX 98 Communication Corp of America KTSM NBC Titan TV KDBC CBS

Ft. Smith‐Fayetteville‐Springdale‐Rogers, AR 100 NexStar Broadcasting Group KNWA NBC NexStar Broadcasting Group KFTA FOX Johnstown‐Altoona, PA 101 Peak Media WWCP FOX Palm Television WATM ABC

Greenville‐New Bern‐Washington, NC 103 Bonten Media Group WCTI ABC Esteem Broadcasting of North Carolina WFXI FOX Lincoln and Hastings‐Kearney, NE 105 Pappas Telecasting KWNB ABC Omaha World‐Herald KFXL Fox Fort Wayne, IN 107 Granite Broadcasting Corp. WISE NBC Malara Broadcasting Group WPTA ABC Tyler‐Longview(Lufkin and Nacogdoches), TX 109 Communication Corp of America KETK NBC White Knight Broadcasting KFXK Fox Youngstown, OH 110 New Vision Television WKBN 27.1 CBS Parkin Broadcasting WYTV ABC Augusta, GA 114 WJBF ABC Schurz Communications WAGT NBC Peoria‐Bloomington, IL 116 Granite Broadcasting Crop. WEEK NBC Barrington Broadcasting WHOI ABC Peoria‐Bloomington, IL 116 NexStar Broadcasting Group WMBD CBS Sinclair Broadcast Group WYZZ FOX 57 Identified Instances of Common Control of Multiple Big 4 Network Stations in the Same Market

Station #1 Station #2 DMA DMA Rank Owner (also Controlling Entity) Call Letters Affil. Owner Call Letters Affil. Traverse City‐Cadillac, MI 117 Barrington Broadcasting WPBN NBC Tucker Broadcasting of Traverse City WGTU ABC Fargo‐Valley City, ND 121 Hoak Media Corp. KVLY NBC Parker Broadcasting KXJB CBS Monterey‐Salinas, CA 124 Cowles Publishing KION CBS Seal Rock Broadcasters KCBA Fox Columbus, GA 128 Raycom Media WTVM ABC Southeastern Media Holdings WXTX FOX Corpus Christi, TX 129 Cordillera Communications KRIS NBC Eagle Creek Broadcasting KZTV CBS Amarillo, TX 131 NexStar Broadcasting Group KAMR NBC Mission Broadcasting KCIT FOX Wilmington, NC 132 Raycom Media WECT NBC Southeastern Media Holdings WSFX FOX Rockford, IL 134 NexStar Broadcasting Group KQRF FOX Mission Broadcasting WTVO ABC Monroe, LA‐El Dorado, AR 138 Hoak Media Corp. KNOE CBS Parker Broadcasting KAQY ABC Monroe, LA‐El Dorado, AR 138 NexStar Broadcasting Group KARD FOX Mission Broadcasting KTVE NBC Duluth, MN‐Superior, WI 139 Granite Broadcasting Crop. KBJR & KRII NBC KDLH CBS Lubbock, TX 143 NexStar Broadcasting Group KLBK CBS Mission Broadcasting KAMC ABC Erie, PA 146 NexStar Broadcasting Group WJET ABC Mission Broadcasting WFXP FOX Erie, PA 146 SJL of Pennyslvania WICU NBC WSEE CBS Joplin, MO‐Pittsburg, KS 147 NexStar Broadcasting Group KSNF NBC Mission Broadcasting KODE ABC Joplin, MO‐Pittsburg, KS 147 Saga Communications KOAM CBS Surtsey Media KFJX FOX Sioux City, IA 148 Titan Broadcast Group (TTBG) KPTH FOX Waitt Broadcasting KMEG CBS Wichita Falls, TX‐Lawton, OK 149 NexStar Broadcasting Group KFDX NBC Mission Broadcasting KJTL FOX Wichita Falls, TX‐Lawton, OK 149 Drewry Broadcast Group KSWO ABC Hoak Media Corp. KAUZ CBS Terre Haute, IN 152 NexStar Broadcasting Group WTWO NBC Mission Broadcasting WFXW FOX

Rochester, MN‐Mason City, IA‐Austin, MN 153 Quincy Newspapers NBC KTTC SagamorHill Broadcasting KXLT FOX Idaho Falls‐Pocatello, ID 162 Sunbelt Communications Co. KPVI‐DT NBC Compass Communications KFXP FOX Abilene‐Sweetwater, TX 165 NexStar Broadcasting Group KTAB CBS Mission Broadcasting KRBC NBC Billings, MT 169 NexStar Broadcasting Group KSVI ABC Mission Broadcasting KHMT FOX Utica, NY 170 NexStar Broadcasting Group WFXV FOX Mission Broadcasting WUTR ABC Grand Junction‐Montrose, CO 184 Hoak Media Corp. KREX CBS Parker Broadcasting KFQX CBS San Angelo, TX 198 NexStar Broadcasting Group KLST CBS Mission Broadcasting KSAN NBC Ottumwa, IA‐Kirksville, MO 200 Barrington Broadcasting KTVO ABC Ottumwa Media Holdings KYOU FOX Victoria, TX 204 Saga Communications KAVU ABC Surtsey Media KVCT FOX